The accounting officer of an organ of state or the owner of a building as contemplated in the EPC Regulation clause 3(1) and 3(2) need to acquire the services of a SANAS Accredited Inspection Body to do the assessment of a building or buildings that meet the requirements as per EPC Regulation 3(1)( c ) or 3(2)(c) and after assessment will issue the certificate. See the following link that lists SANAS Accredited IBs and choose the one most suitable to work with:

Considering the varying complexities of buildings occupancy classes, building size, data collection methods and approach, and other contributing factors, each building and project cost will be unique. It is therefore dependent on the discussion and negotiations with the SANAS Accredited Inspection Body to reach an amicable cost

To understand the cost of an EPC it is important to keep in mind that an EPC can only be issued by SANAS accredited EPC inspection bodies. This ensures that energy performance certifications are done according to the relevant standards and that the individuals performing the certification work have appropriate qualifications, training, and experience.

Furthermore, for an inspection body to issue an EPC, comprehensive data collection, validation and analysis are required – all done by competent inspection body staff.

The EPC related costs can be mitigated if the property owner collects all required data and makes this easily accessible to the inspection body.

To become an EPC Inspection Body, an organization/business must receive an EPC Accreditation from SANAS.

To initiate the accreditation process, the interested party must contact either one of the following SANAS representative, who will issue the interested party with the application package and assign them an accreditation number:

In the case of a multi occupancy (say commercial offices and a place of tuition or learning in one building).The assessment will be made using submetering per occupancy class. Any occupancy with less than 10% of net floor area will be included in the dominant occupancy. So, if the office component is less than 10% of the total property size, the office can be included in the “industrial occupancy class” of the property (and therefore would not need an EPC as it is not one of the occupancy classes listed above).

Exceptions are:

1) If the energy consumption of the office component is more than 10% of the total energy consumption of the property, then the office must be treated as a separate occupancy class, and then,

2) If the office area is > 2000 m2, this office component would need an EPC.

The mandated occupancy classes are specified and exhaustively listed in the National Building Regulations, Regulation A20 and they are:

A1 – Entertainment and public assembly: Occupancy where persons gather to eat, drink, dance or participate in other recreation. Typical examples of this occupancy type are restaurants, night-clubs, sports pubs, gyms and so forth. The size threshold of 2 000 m2 (for privately owned buildings) make this an occupancy class that is not likely to result in many certifications, compared to the G1 – Office occupancy class.

A2 – Theatrical and indoor sport: Occupancy where persons gather for the viewing of theatrical, operatic, orchestral, choral, cinematographically or sport performances. Typical examples include movie theatres, live theatres and so forth.

A3 – Places of instruction: Occupancy where school children assemble for the purpose of tuition or learning and occupancy other than primary or secondary schools, where students or other persons assemble for the purpose of tuition or learning. This occupancy class would typically include schools, colleges, universities and Technikons.

G1 – Offices: Large multi-storey office buildings, banks, consulting rooms and similar uses with lifts and energy consuming services that operate on a typical daytime occupancy and stand-alone blocks and / or a campus of buildings that form an office park but operate separately

Only building belonging to the occupancy classes in 7 above i.e. A1, A2, A3 and G1 as defined in the National Building regulations must display and EPC by the 07 December 2022 deadline.

There are no legislated penalties for a poor EPC rating. However, the rating on an EPC could play a role in attracting and retaining tenants and have an impact on the resale value of a property. Time will tell on what degree a buildings EPC rating translates to economic impact, whether positive or negative, for the property owner.

The following example is a “standard” Energy Performance Certificate as shown in SANS 1544:2014.

 Figure 1 – A pro-forma EPC (from SANS 1544:2014)

An EPC must be at least 14 x 19cm in size and must be publicly displayed in the building for which it has been issued.

“The installation of a solar PV plant as the only building improvement will not change the EPC rating of a building. Only energy efficiency improvements that reduce the kWh/m2/annum of the building will improve a building’s rating”

The answer is YES. Using diesel fuel will adversely affect the energy performance of a building. SANS 1544:2014 requires the inclusion of the energy value in kWh of any liquid fuel (for example diesel) used during the year of assessment to determine the building Net Energy Consumption. Most buildings use diesel fuel in backup generators to provide electricity to a building when there is an interruption in the grid supplied electricity (e.g., during loadshedding). Energy is lost in the form of heat and noise during the conversion of diesel energy to electrical energy in the generator.

Therefore, the use of energy from a diesel-generator results in an energy footprint larger than that from using grid electrical energy.

It is challenging to issue an EPC for buildings without any usable floor plans. A building’s rating is very dependent on building size (the net floor area (NFA)), as defined in SANS 1544 and an EPC inspection body must go through significant effort to determine the NFA as accurately as possible. Without any floor plans, the likely options are to either suspend certification activities to afford the property owner the opportunity to find the “missing” floor plans OR to draught new floor plans for the building.

According to the National Energy Act (No. 34 2008) penalties for contravening the Act in which the EPC regulations are derived from, may receive a fine not exceeding R5 million and/or imprisonment for a period not exceeding 5 years if convicted . This penalty applies to both private and state-owned buildings that meet the criteria for the mandatory display of an EPC.

The inception of the development of the EPC commenced mid-2010 with the issuing of SANS 204: Energy Efficiency in Buildings and SANS 10400 XA: Energy Usage In Buildings. This was followed by the issuing of SANS 1544: Energy Performance Certificate Standard in 2014.

Then the draft regulations for the mandatory display and submission of energy performance certificates for buildings (the EPC regulations) was gazetted for public comment in July 2018. The implementation of the EPC regulations in December 2020 should not really have been a surprise and it could be argued (from a DMRE point of view) that there has been ample time to comment on the standard as well as the regulations.

It would therefore be incumbent on accounting officers to obtain certifications as soon as possible, such that they are compliant before the deadline of 07 December 2022.

The latest EPC regulation declares the EPC deadline to be two years from the promulgation of the regulation as of 08 December 2020. This makes the EPC deadline to be on the 07 December 2022. This has not changed. If any regulation amendments occurs, the DMRE will communicate through relevant channels at the time of consideration.

The SANEDI websites on the following link provides a list of the accredited EPC inspection bodies. Be sure to ask any prospective EPC service provider for their proof of SANAS accreditation before appointing your EPC Inspection Body.

https://www.sanedi.org.za/SANAS_Certificates.html

Only a SANAS-accredited EPC inspection body can issue a building energy performance certificate. A building owner can use internal staff or contract the services of other consultants to assist with the gathering of information required by the inspection body, but the actual certification must be done by an accredited EPC inspection body.

Develop and implement an energy efficiency strategy for the building. This can include the following:

• Replace incandescent light bulbs with LED lighting
• Replace geysers with heat pumps (if hot water is used)
• Optimise the setpoints of the air-conditioning system
• Encourage the use of stairs to mitigate the use of the elevators
• Insulate the building thoroughly
• In general installation of energy efficient technologies

No.
SANS 1544: 2014 defines the Net floor Area (NFA) as the sum of all areas between the vertical building components (walls or partitions), excluding garages, car parks and storerooms.

EPCs are an internationally recognised tool to assess the energy efficiency of buildings. An understanding of the baseline energy efficiency (kWh/m2) of buildings is the starting point to achieving required improvements to buildings energy efficiency and this is what South Africa’s EPC mechanism will set out to achieve.

In most countries EPCs play an important role in providing the ability to map the building stock energy efficiency at a national scale; to monitor the impact of building policies and to support the introduction of new minimum energy efficiency requirements within the regulatory process, and to help enable robust carbon reporting and target setting in relation to the building sector.

EPC mechanisms drive change by driving measurement and profiling of buildings, which can then prompt improvements. An EPC database can be used for identifying energy efficiency interventions across the building stock, and for carbon/climate reporting and target setting.

Yes. An EPC shows the energy performance of the building against an appropriate benchmark, and therefore directly relates to sustainability.

It should not take very long to obtain an EPC. The biggest challenge (and the most time-consuming step) of the certification process is usually associated with the preparation of the information needed by the EPC inspection body.

This data includes consumption data (for all the energy sources used by the building), floor plans and occupancy data. For property owners with large portfolios the information gathering challenges can be exacerbated by the complexity of the data required.

Getting an early start on this is important to achieve compliance by the deadline. Many property owners (but not all) got an early start on this and started to gather building information even before appointing an EPC inspection Body.

Once a property owner can hand a “building information pack” to the EPC inspection Body, the process of issuing an EPC should not take more than 10 working days. With sufficient resources, an EPC inspection body should be able to issue several EPCs per week, provided that the information packs for these buildings have been prepared by the property owner.

The following steps are a guideline for the display and submission of an EPC by the Accounting Officers.

1. Identify which buildings, or portions of buildings, need EPCs. A SANAS accredited EPC inspection body can assist with this step (see the next point).

2. Identify SANAS accredited EPC inspection bodies who can deliver the certifications. There is a small window of opportunity (lasting another 2-3 months) to secure the services of an accredited EPC inspection body, before the demand for energy performance certification services far exceeds the available EPC inspection bodies’ capacity in the market.

3. Understand the costs of EPCs and make budgetary provision to have the certifications done.

4. Gather the information needed by an EPC inspection body. This must start as soon as possible as EPC “information risk” (i.e., the risk that information needed for certification is not available) is the biggest risk to achieve certification. The information that must be made available to the EPC inspection body includes:

• • As-built floor plans
• • Internal layout plans
• • Grid consumption “data” files (e.g., bulk check meter load profiles and/or municipal accounts)
• • Invoices for diesel purchased
• • Invoices for gas purchased
• • Solar PV production and consumption data (load profiles)
• • Invoices for coal purchased (hopefully not too many of these)
• • Information relating to energy exported from buildings
• • Occupancy data
• • Building operating hours, especially where a building or a part of a building is operated outside of the SANS 10400 “norm”. An example would be a call center in an office building that operates 24/7, compared to the typical operating hours of an office building as listed in SANS 10400-XA. The typical operating hours of an office is 12/ 5.

5. Brief internal staff (asset managers, building managers, other stakeholders) on the importance of EPCs and what their contribution can and must be to ensure compliance.

6. Arrange EPC roll-out planning sessions (with the EPC inspection body) to schedule and plan the delivery of EPCs according to numerous factors like building location, information availability, building complexity and so forth (this varies on a case-by-case basis).

The person who will be the owner of the building by the EPC deadline of 7 December 2022 will be held responsible for the display of the EPC.

It is estimated that the total EPC market is between 250 000 and 350 000 buildings for the occupancy classes currently included in the regulations. Many of these buildings are owned by organs of state, but the number of privately owned buildings are also likely to be well into the tens if not hundred(s) of thousands.

The penalty only applies to the buildings that meet the criteria for mandatory energy performance certification. Buildings that do not meet the criteria may consider voluntary certification and will not be penalized.

The regulation for the mandatory display of an energy performance certificate stipulates those buildings owned by an organ of state that belong to the specified occupancy classes and which exceeds 1000 m2 need an EPC.

An EPC building rating must reference the new SANS10400XA:2021 document when the certification work starts in or after May 2022.

You may contact the SANEDI representative on the following details

Mr. King Modingoana
[email protected]
011 038 4320

Enquiries will be responded to, as soon as possible